TPA - Arms length price (ALP) - AO has mentioned that the payment made to the AE was excess and...

TPA - Arms length price (ALP) - AO has mentioned that the payment made to the AE was excess and unreasonable. But, not a single word has been uttered in the order as to how it was excess or not reasonable. Any disallowance or addition, whether under chapter IV or chapter X of the Act, cannot be made on ad hoc basis - AT .....

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